BEPS Transfer Pricing Documentation and Country by Country Reporting. David Perrone, Senior Manager

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1 BEPS Transfer Pricing Documentation and Country by Country Reporting David Perrone, Senior Manager

2 Country-by- Country Reporting 1

3 Country-by-Country Template Country Related Party Revenue Unrelated Party Total Profit (Loss) Before Income Tax CbyC Template Page 1* Income Tax Paid (on a Cash Basis) Income Tax Accrued Current Year Stated Capital Accumulate d Earnings Number of Employees Tangible Assets Other than Cash and Cash Equivalents Country A X X X X X X X X X X Country B X X X X X X X X X X CbyC Template Page 2* (Onwards) Activities Country Constituent Entities Resident in Country Country of Organisation or Incorporation if different from Country of Residence R&d Holding or Managing IP Purchasing & Procurement Manufacturing & Production Sales, Marketing & Distribution Administrative, Management & Support Services Provision of services to unrelated parties Internal Group Finance Regulated Financial Services Insurance Holding shares or other equity instruments Dormant Other Country A Entity A Country B Entity B *Information obtained from Annex III to Chapter V of OECD/G20 Base Erosion and Profit Shifting Project: Guidance on Transfer Pricing Documentation and Country-by-Country Reporting 2

4 Country-by-Country Reporting Template Category Content Key Issues Challenges Financial Reporting Revenues, EBIT, Taxes Paid Determine top-down or bottom-up approach Economic Substance Timing Number of Employees, Tangible Assets Ensure Master File provides context for these data to prevent misinterpretation/misuse by tax authorities (i.e., provide context/explanation for high revenueslow taxes paid low employees situations, as well as for contractual allocation of risk) Determine optimal timing and consistency with Master and Local Files Reconciliation of any large differences between statutory and financial statement reporting Data gathering and validation Authorities could rely on these data as proxies for economic activity and implicitly apply a formulary apportionment approach in resulting transfer pricing adjustments Different timing for tax returns and statutory financials 3

5 Master File 4

6 Master File Content Chart illustrating the MNE s legal and ownership structure and geographical location of operating entities Important drivers of business profit Supply chains for five largest products/services Main geographic markets for five largest products/services Brief functional analysis, including key functions performed, important risks, and assets A list and brief description of important service arrangements between members of the MNE group, other than research and development (R&D) services, including description of capabilities and transfer pricing policies A description of important business restructuring transactions, acquisitions and divestitures occurring during the fiscal year Typically Provided in Existing Transfer Pricing Documentation t globally t globally t globally t globally Key Issues Treatment of PEs and other definitional issues Consistency across various reports and other documents (e.g., annual reports, APAs, local documentation, other regulatory filings) Consistency with transfer pricing and global profit allocation per Country-by- Country Report Compiling necessary information and presenting in a timely and organized manner Determining necessary amount of detail to provide 5

7 Master File (continued) Content A general description of the MNE s overall strategy for the development, ownership and exploitation of intangibles, including location of principal R&D facilities and location of R&D management A list of intangibles or groups of intangibles of the MNE group that are important for transfer pricing purposes and which entities legally own them A list of important agreements among identified associated enterprises related to intangibles, including cost contribution arrangements, principal research service agreements and license agreements A general description of the group s transfer pricing policies related to R&D and intangibles. A general description of any important transfers of interests in intangibles among associated enterprises during the fiscal year concerned, including the entities, countries, and compensation involved Typically Provided in Existing Transfer Pricing Documentation t globally t globally t globally Key Issues Clear delineation of key decision-making functions versus execution functions and consistency with profit allocation per Country-by-Country Report Treatment of ambiguous intangibles such as manufacturing know-how, marketing intangibles, etc. Maintain list of intercompany agreements that include appropriate contractual terms Should be consistent with sections on identification and functional description of intangibles 6

8 Master File (continued) Content A general description of how the group is financed, including important financing arrangements with unrelated lenders The identification of any members of the MNE group that provide a central financing function for the group, including the country under whose laws the entity is organized and the place of effective management of such entities A general description of the MNE s general transfer pricing policies related to financing arrangements between associated enterprises The MNE s annual consolidated financial statement for the fiscal year concerned if otherwise prepared for financial reporting, regulatory, internal management, tax or other purposes A list and brief description of the MNE group s existing unilateral advance pricing agreements (APAs) and other tax rulings relating to the allocation of income among countries Typically Provided in Existing Transfer Pricing Documentation t globally, but typically available Key Issues Interaction with other BEPS actions on financing (e.g., hybrid mismatch, interest deduction, and risk and capital) Interaction with other BEPS actions on financing (e.g., hybrid mismatch, interest deduction, and risk and capital) Potential impact on global tax risk profile of disclosures 7

9 Local File New Material in Addition to Typical, Existing Transfer Pricing Documentation 8

10 Local File Content A description of the management structure of the local entity, a local organization chart, and a description of the individuals to whom local management reports and the country(ies) in which such individuals maintain their principal offices Copies of all material intercompany agreements concluded by the local entity A copy of existing unilateral and bilateral/multilateral APAs and other tax rulings to which the local tax jurisdiction is not a party and which are related to controlled transactions described above Annual local entity financial accounts for the fiscal year concerned. If audited statements exist they should be supplied and if not, existing unaudited statements should be supplied Information and allocation schedules showing how the financial data used in applying the transfer pricing method may be tied to the annual financial statements Typically Provided in Existing Transfer Pricing Documentation Key Issues Explanation of reporting relationships. For example, multiple reporting situations (e.g., regional, product line) Availability of intercompany agreements Timing of availability of local entity financial statements Information system and financial reporting group support for reconciling discrepancies 9

11 Local File (continued) Content A detailed description of the business and business strategy pursued by the local entity including an indication whether the local entity has been involved in or affected by business restructurings or intangibles transfers in the present or immediately past year and an explanation of those aspects of such transactions affecting the local entity The amount of intra-group payments and receipts for each category of controlled transactions involving the local entity (i.e., payments and receipts for products, services, royalties, interest, etc.) broken down by tax jurisdiction of the foreign payor or recipient A detailed comparability and functional analysis of the taxpayer and relevant associated enterprises with respect to each documented category of controlled transactions, including any changes compared to prior years (To the extent this functional analysis duplicates information in the master file, a cross-reference to the master file is sufficient.) Typically Provided in Existing Transfer Pricing Documentation Yes, but often not as detailed Yes, but often not as detailed Yes, but often not as detailed Key Issues Narrative needs to be consistent with the Master File and local files for other entities Information system support 10

12 2014 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ( KPMG International ), a Swiss entity. All rights reserved. NDPPS The KPMG name, logo and cutting through complexity are registered trademarks or trademarks of KPMG International.

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